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After they joined CAST, petitioners continued to consult with Mr.
Taylor about five times a week.
Petitioners also continued to study and perfect new
techniques to improve the quality and profitability of their
fishing activity. In time, petitioners, themselves, became
experts who were relied upon by other CAST directors. Petitioner
is now a Supervising Director with three regions reporting to him
and his gross receipts from the fishing activity will continue to
grow as more regions are created.
Though there is no question that petitioners derive pleasure
from their fishing activity, and petitioners concede that they
fish in their own tournaments on occasion, petitioners’ passion
for fishing does not disqualify them from having a profit
objective. The process of organizing and hosting a fishing
tournament is physically difficult and requires long hours of
work, and, in this case, far outweighs whatever personal pleasure
petitioners derive from occasional participation in their own
tournaments.
Although petitioners sustained losses during the first 5
years of their fishing activity, this alone does not necessarily
indicate that the activity was not engaged in for profit. See
Churchman v. Commissioner, 68 T.C. 696 (1977).
In Zwicky v. Commissioner, T.C. Memo. 1984-471, the
taxpayers operated a charter fishing boat service and sustained
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